Modification Proposal 115 – ‘Correct Apportionment of NDM Error’ Graham Wood

Mod 115 Presentation Development activity since the last Distribution Workstream Purpose of Modification Proposal Potential Solution – Smearing Element EUC Bands & Charging AMR Scenarios Next Steps

Modification Proposal Further development of the proposal has taken place with Xoserve since the last workstream. Clarity of the intent of the original proposal: To smear all unreconciled and reconciled LSP energy, which is currently smeared via RbD solely across the SSP sector (RbD Shippers), more equitably across all NDM supply points and Shippers.

Potential Solutions – Smearing Element Continuation of existing process with use of an off-line adhoc invoice to include additional parties Ad-hoc invoices to be issued on a monthly basis, with a month after re-allocation per market sector Annual % figure of SSP & LSP market share per shipper, to be agreed and applied

Potential Solutions – EUC Bands The existence of different transportation charges for each EUC Band is problematic: It makes the potential solution very complex Not easy to apply within market / governance arrangements Potential to use a single rate: Would provide a more simplistic solution Potential inappropriate allocation of charges Alternative solution: Use of a weighted average possibly the most appropriate way forward Further requirement to assess impacts associated with this option

AMR Recognised by previous discussions that the exclusion of AMR sites from the proposal will significantly complicate the solution required to implement. Changes will be required to sites and meters and associated flows to appropriately identify AMR meters Requirement to update sites and meters after asset change Requirement to update sites and meters after change of supply Potential risk that sites below the 73,200 kWh threshold would never reconcile. A site or meter with AMR equipment or capability may not be being actively utilised. The relatively simple off-line invoice solution would not be able to be utilised with AMR sites excluded. A more fundamental and costly systematised solution would be required. Implementation timescales would be extended.

Scenarios Further to discussions to date a number of scenarios are presenting themselves: Smear all energy across all NDM supply points, with the exclusion of AMR supply points (original proposal) Smear all energy across all NDM supply points, with inclusion of AMR supply points Smear a formulated percentage of energy across all NDM supply points, with the exclusion of AMR supply points Smear a formulated percentage of energy across all NDM supply points, with the inclusion of AMR supply points

Next Steps Further consideration of scenarios Development of proposal solution with Xoserve and Gas Transporters Provision of a defined timetable for development work Refinement of modification as appropriate